SAFEdge Web Privacy Policy (U.S.)
This Web Privacy Policy explains how SAFEdge Investment Management LLC (“SAFEdge”) collects, uses, shares, and protects information when you visit the website at safedgefund.com. This policy applies to visitors to the Site who are located in the United States. Additional privacy disclosures applicable to investors in funds advised by SAFEdge are provided in the relevant fund documents.
About SAFEdge and the Services
SAFEdge is a California exempt reporting adviser providing discretionary investment management services to pooled investment vehicles. SAFEdge does not provide investment advisory services directly to individual retail clients through the Site.
Information We Collect
SAFEdge collects information you provide directly and information generated by your use of the Site. Information you provide may include identifiers and contact details such as name, email address, and telephone number; professional affiliation and role; and communications you send to SAFEdge. Information generated by your use of the Site includes device and usage information such as IP address, browser and device characteristics, operating system, referring and exit pages, timestamps, approximate location inferred from IP address, pages viewed, and diagnostic logs. SAFEdge does not collect personal information from investors in funds it advises through the Site; such information is collected through separate channels and governed by fund documents and applicable investor disclosures.
How We Use Information
SAFEdge uses information to operate, maintain, and improve the Site; respond to inquiries and communications; conduct analytics and service development; comply with legal obligations and enforce terms; and protect the Site and users, including through security monitoring. SAFEdge may de-identify or aggregate information and use or disclose such de-identified or aggregated information for any purpose, including to improve the Site.
How We Share Information
SAFEdge shares information for limited purposes. SAFEdge shares information with service providers that perform services on its behalf, such as cloud hosting, security, and analytics. These service providers may use information only to provide contracted services and must protect it appropriately. SAFEdge may share information with its affiliates to help operate the Site. SAFEdge may share information to comply with law, regulation, legal process, or regulatory requests; to protect the rights, property, or safety of SAFEdge, users, or others; or to detect, prevent, and respond to fraud, security, or technical issues. If SAFEdge engages in a corporate transaction such as a merger, acquisition, financing, or sale of assets, information may be shared or transferred as part of that transaction, subject to continued protections consistent with this policy. SAFEdge does not sell your personal information and does not share your personal information with third parties for their own marketing purposes.
Information may be transferred to and processed in countries other than the United States, which may have different data privacy laws than those of the United States. By using the Site, you consent to the transfer of information to these countries.
Cookies and Similar Technologies
SAFEdge may use cookies and similar technologies to operate the Site, remember preferences, maintain session security, and understand service usage. You can manage cookies through your browser settings; some features may not function properly without certain cookies. SAFEdge uses analytics to understand how the Site is used and to improve performance but does not use cookies or similar technologies for cross-context behavioral advertising. If SAFEdge’s use of cookies changes in a way that requires additional disclosures or choices, SAFEdge will update this policy and, where required, provide additional notice.
Retention
SAFEdge retains information for as long as needed to operate the Site and for other legitimate purposes, including to comply with legal, regulatory, and recordkeeping requirements applicable to investment advisers, to resolve disputes, and to enforce agreements. Retention periods vary based on the nature of the data and applicable obligations.
Your Choices and State Privacy Rights (including California)
You can update personal information and manage email preferences by following instructions in SAFEdge emails or by contacting SAFEdge. You can manage cookies through your browser settings.
Depending on where you live, you may have rights under applicable state privacy laws to request access to, deletion of, or correction of your personal information, and to receive information about SAFEdge’s practices. SAFEdge will honor requests as required by law. Note that certain information may be exempt from such requests under applicable law, including information subject to the Gramm-Leach-Bliley Act or collected in a business-to-business context.
For California residents, SAFEdge provides the following additional information pursuant to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”): SAFEdge does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under California law. SAFEdge does not use or disclose sensitive personal information for purposes other than those permitted under CCPA/CPRA. You may request access to the categories and specific pieces of personal information SAFEdge has collected about you, request deletion of personal information, and request correction of inaccurate personal information, subject to applicable exceptions. SAFEdge will not discriminate against you for exercising your rights. Note that much of the personal information SAFEdge collects may be exempt from certain CCPA/CPRA requirements under the Gramm-Leach-Bliley Act exemption or the business-to-business communications exemption. To submit a verifiable consumer request, contact SAFEdge using the information provided below. If SAFEdge’s practices change in ways that would require a notice at collection or additional disclosures, SAFEdge will update this policy and, where required, provide additional notice.
Security
SAFEdge maintains administrative, technical, and physical safeguards designed to protect information. These include access controls, encryption in transit and at rest where appropriate, network and application security, monitoring and logging, vendor due diligence and contractual safeguards for service providers, and incident response processes. If SAFEdge determines that an unauthorized party has accessed sensitive personal information, SAFEdge will provide notices as required by applicable law.
Children’s Privacy
SAFEdge’s Services are not directed to children under the age of 13, and SAFEdge does not knowingly collect personal information from children under 13. If SAFEdge learns that information has been collected from a child under 13, SAFEdge will delete it.
Electronic Delivery and Records
SAFEdge communicates electronically consistent with agreements shared with you by SAFEdge. Please review that consent for information about electronic delivery and your choices.
Changes to This Policy
SAFEdge may update this Web Privacy Policy from time to time to reflect changes in practices or legal requirements. SAFEdge will post the updated policy on the Site with a new effective date and, when required, will provide additional notice.
How to Contact Us
You can contact SAFEdge about this policy or to exercise privacy rights by emailing girish@gaitonde.net, by mail at 10080 North Wolfe Road, Suite SW3-200, Cupertino, CA 95014, or by phone at 408-872-1555.